Customs and Trade Facilitation
James Min, Vice President, International Trade Law & Compliance Legal Department - DHL Americas, DHL Express USA, Inc., TIACA
Sue Presti, Senior Director of Government Affairs, TIACA
Gordon Wright, Senior Manager, Cargo Security Processes & Standards, IATA
Christian Piaget, Manager Cargo Customs & Claims, IATA
Daniel Bloch, Manager Airfreight Institute and Customs Affairs Institute, FIATA
Bassil Eid, Manager ABIT, FIATA
Bruce Carlton, President & CEO, NITL, GSF
Albert Saphir, Principal, ABS Consulting, GSF
The recommendations from the GACAG Customs and Trade Facilitation Task Force will mainly focus on the following areas:
- Customs modernization
- Customs automation
- Customs advance data collection and targeting
- Ongoing customs initiatives within the World Customs Organization
- The World Trade Organization's negotiations on trade facilitation
- Ad hoc air cargo customs and trade facilitation issues
Paperless Environment for Air Cargo Imports and Exports
GACAG supports a paperless operating environment for air cargo imports and exports. Ultimately, we would like to see the processing and authorization of secured data to be shared between air cargo operators and relevant participating government agencies in a single data transfer set.
To move toward a paperless environment, we need collaboration and cooperation from customs and other border authorities. We will continue pursuing this objective at the WCO. We believe the WCO should review the need for and value of all existing supporting documents, and replace those deemed necessary with equivalent electronic messages, in an internationally standard format.
GACAG supports national initiatives to establish and implement paperless environments. We believe that, at a minimum, the following should be accomplished through electronic means:
- Export and import goods declarations to customs from exporters, importers and/or their forwarders or customs brokers;
- Export, import and transit cargo declarations to customs from airlines;
- Supporting documents should be provided by exception only (e.g. in case of an examination) and printout of electronic records should be accepted;
- Air waybill, house waybill and manifest transport documents exchanged between forwarders and airlines and only provided to customs exceptionally – not regularly;
- All key commercial documents (e.g. commercial invoice, packing list, hazardous materials documentation, certificates of origin) when needed;
- Record-keeping and archiving for all participating parties (shippers, forwarders, airlines, etc.). There should be no requirement for participating parties to print documents (for example, complete airline manifest and supporting printout for all U.S. departed flights) unless by exceptions (e.g. in case of an audit), and printout of electronic records should be accepted.
For more information, check the GACAG Position Paper on Communications with Regulators (pdf)
Advance Cargo Data Collection & Targeting
Advanced Cargo Information for Air Cargo Shipments
GACAG understands and supports the need for comprehensive risk assessment of air cargo shipments. Countries must protect their citizens, just as our industry must protect employees and assets. A verified secure supply chain is one of the ways this can be accomplished with traders, forwarders, ground handlers and airlines all fulfilling their important roles. GACAG seeks to achieve a system which advances a safe and secure supply chain while maintaining the flow of international commerce.
With respect to the issue of advance data, GACAG supports:
- Open dialogue between industry and government on this issue.
- A pilot approach, in which industry and government jointly evaluate every stage of the process. Both industry and government should be willing to make adjustments based on ongoing evaluations.
- The principle of dual filing where forwarders can file their detailed reports on behalf of their customers while airlines report their manifest level reports, whenever possible.
- Clarity regarding which party is responsible for which specific data.
- Operationally feasible requirements.
To learn more, download the GACAG Position Paper on on Air Cargo Advance Electronic Data for Security Purposes (pdf)
Harmonization of Standards
GACAG wants to underline the importance of harmonized, global standards. For example, automation systems should require only those data elements that are legitimately needed to ensure compliance with pertinent regulations, and should be in standardized, harmonized formats. A plethora of national standards increases the costs and inefficiencies of our operations, which span the globe, so we have a keen interest in this subject.
- There should be a global standard of the minimum data elements required for air cargo shipments. The standard should be aligned with the WCO Safe Framework of Standards and, if not already in, it should be incorporated into the WCO Data Model.
- As we move towards possible consideration of advance data at the global level, it will be critically important to work toward harmonized standards. It is imperative that both governments and industry agree and accept a standard set of data elements that can be transmitted, received and authorized for the secure movement of air cargo in accordance with the WCO SAFE Framework of Standards. Any deviation from a solid standard will only increase cost, delay movement, and ultimately reduce security and secure data.
For more information, read the GACAG Position Paper on Customs Harmonization (pdf)